This webinar examines signals from Government and the finance community about the need for mandatory disclosure and potential pathways for inclusion of the TCFD recommendations into national legislation.
Webinar slides: Are we headed towards mandatory climate reporting?
1. September 19 | Tweet @CDSBGlobal
Jennie Gleed, Senior Policy Manager, CDP
Are we headed towards mandatory
climate disclosure?
Michael Zimonyi, Policy and External Affairs Director,
Climate Disclosure Standards Board (CDSB)
2. September 19 | Tweet @CDSBGlobal
Board
Technical Working Group (examples)
To provide decision-useful environmental
information to markets via the mainstream
corporate report
3. CDP is a global environmental impact non-profit working to secure a thriving
economy that works for people and planet.
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ABOUT CDP
Name | @Twitter
Information is the fundamental basis for action. We help investors, companies and
cities to measure, understand and address their environmental impact.
We aim to make environmental reporting mainstream and provide detailed
insights to drive action for a climate safe, water secure, deforestation free world.
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TCFD recommendations
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Overview
1. Voluntary
2. Report climate-related financial disclosures in
the annual financial filings (mainstream report)
3. Financial sector & high risk non-financial sectors
4. Transition risks & physical risks (and opportunities)
5. Scenario analysis & forward-looking information
6. Short-term, medium-term & long-term
7. Qualitative & quantitative disclosures
Governance
Strategy
Risk
Management
Metrics
and Targets
Are we headed towards mandatory climate disclosure?
5. TCFD recommendations as CDP metrics
Turning guidelines into metrics for investor evaluation
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TCFD recommendations
What investors and companies
should be evaluating.
CDP questions
Breakdown of recommendations
into accessible, actionable
metrics
CDP guidance
How to provide complete,
comparable information for
each question. Resources
to take action on metrics.
CDP scoring
What is best practice for
each metric.
CDP data
Comparable, standardized,
decision-useful
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Are we headed towards mandatory climate disclosure? 6
TCFD implementation
Creating consistent, comparable and decision-useful climate-
related financial disclosures
CDP helps companies
generate, report and
structure their data.
CDSB helps companies
integrate the financially
material information into
their mainstream reports.
TCFD promotes better
decision-making, enhanced
market resilience and more
sustainable economic
growth.
7. September 19 | Tweet @CDSBGlobal
Support for TCFD
Are we headed towards mandatory climate disclosure? 7
825
supporters globally,
responsible for
assets of $118 trillion.
• Belgium
• Brazil
• Canada
• Chile
• European Union
• France
• Ghana
• Hong Kong
• Japan
• Netherlands
• New Zealand
• Singapore
• Sweden
• United Arab Emirates
• United Kingdom
Government
support:
8. Avenues for inclusion of the TCFD
recommendations into national legislation
in G7 jurisdictions
8 @CDP
Roadmap for adopting the TCFD recommendations
9. September 19 | Tweet @CDSBGlobal
France
Are we headed towards mandatory climate disclosure? 9
Article 173 of Energy Transition and Green Growth Law
requires financial stakeholders to publish information on
how ESG criteria, particularly concerning climate risks, are
taken into account.
Only minor adjustments to existing French reporting
practices would be required, such as Article 173 of the
Energy Transition and Green Growth Law, to align French
legislation with the TCFD recommendations.
10. September 19 | Tweet @CDSBGlobal
Japan
• Highest number of TCFD supporters
• Position Japan as leader in TCFD implementation
• TCFD Coalition
• Collaboration with other financial centres globally
• Strong involvement by
– Japan Financial Services Agency
– Ministry of Economy, Trade and Industry
– Japan Exchange Group
Are we headed towards mandatory climate disclosure? 10
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UK
Are we headed towards mandatory climate disclosure? 11
The UK government has set out its expectation for all
listed companies and large asset owners to disclose in
line with the TCFD recommendations by 2022, in it’s
recently released UK Green Finance Strategy.
Updates to implement TCFD
UK could align legislation by strengthening the 2013 & 2017
amendments to the Companies Act 2006 to incorporate
recommended disclosures of the TCFD recommendations in
Directors Reports and/or Strategic reports.
12. September 19 | Tweet @CDSBGlobal
Canada
• CSA Staff Notice 51-358: Reporting of Climate Change-
related Risks
• Final Report of the Expert Panel on Sustainable Finance
– 5.1. Endorse a phased ‘comply-or-explain’ approach to adoption of the
TCFD framework in Canada.
Updates to implement TCFD
• Canadian Business Corporation Act; and/or
• NI 51-102 Continuous Disclosure Obligations & NI 58-101 Disclosure of
Corporate Governance Practices;
• CSA Staff Notice 51-333 Environmental Reporting Guidance to
incorporate TCFD recommendations.
Are we headed towards mandatory climate disclosure? 12
13. September 19 | Tweet @CDSBGlobal
USA
Are we headed towards mandatory climate disclosure? 13
Regulation S-K already requires listed companies to provide
disclosures on items including:
Description of business
Legal proceedings
Risk factors
Management’s discussion and analysis
Updates to implement TCFD
The Securities and Exchanges Commission provides guidance regarding
climate change related disclosure, but enforcement of this has not yet been a
priority for the SEC.
14. September 19 | Tweet @CDSBGlobal
EU
• Non-Financial Reporting Directive provides basis for TCFD
• EC Guidelines on reporting climate-related information
• Commission would be “surprised” if Non-Financial Reporting
Directive was not reopened
• EFRAG Project Task Force on Climate-related Reporting
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Updates to implement TCFD
Art. 19a and 29a of NFR Directive (2014/95/EU) and article 20 of Directive 2013/34/EU with TCFD
recommendations.
European Securities and Markets Authority (ESMA) and Member State National Competent Authorities
provided with the jurisdiction and funding to supervise ESG reporting.
15. September 19 | Tweet @CDSBGlobal
Australia
AASB Practice Statement on Climate-related and other emerging risks
disclosures
• asset impairment;
• changes in the useful life of assets;
• changes in fair valuation of assets due to climate-related and emerging risks;
• Chenge in costs and/or demand for products & services affecting impairment
• Provisions and contingent liabilities arising from fines and penalties; and
• Vhanges in expected credit losses for loans and other financial assets.
ASIC – climate change is ’systemic risk’
• Regulatory Guide 228 Prospectuses: Effective disclosure for retail investors;
• Regulatory Guide 247 Effective disclosure in an operating and financial review
Are we headed towards mandatory climate disclosure? 15
16. September 19 | Tweet @CDSBGlobal
New Zealand
Productivity Commission recommendations – Aug 2018
R7.4 The Government should implement mandatory (on a comply or explain basis),
principles-based, climate-related financial disclosures by way of a standard under
section 17(2)(iii) of the Financial Reporting Act 2013. These disclosures should be
audited and accessible to the general public.
Government response – Aug 2019
The Government agrees... To achieve this further consideration is required in
relation to the following matters:
1. Whether the Financial Reporting Act is the most appropriate means for
implementing climate-related disclosure requirements.
2. Consideration of the classes of entities the disclosure requirements should
apply to. Subject to consultation, the Government considers that listed issuers,
registered banks and licensed insurers should be covered. It is less clear
whether any other classes of entities should also have climate-related
disclosure requirements.
3. What, specifically, the disclosure requirements should require entities to disclose
and whether the disclosures should be different for different classes of entity.
Are we headed towards mandatory climate disclosure? 16
17. September 19 | Tweet @CDSBGlobal
Chile
• Chilean Sustainable Finance Public-Private Working Group
• Sector-specific transition plans for key sectors (EY Chile)
• Mandatory climate change requirements
– Norma de Carácter General n°30;
– Delivering complete, consistent and decision-useful
information to investors;
– Public consultation in “next few weeks”
“So far climate change hasn't been a relevant topic in the agenda
of our financial markets but this has to change.”
– Joaquín Cortez, CMF
Are we headed towards mandatory climate disclosure? 17
18. September 19 | Tweet @CDSBGlobal
Are we heading towards mandatory
disclosure?
• Other jurisdictions, e.g.: China
• Not “if”, but “when” and “who”
• Evolution, not revolution – small tweaks & enforcement
• TCFD must remain focal point
• Paris Agreement
Are we headed towards mandatory climate disclosure? 18
cdsb.net/G7
Nadine: The Climate Disclosure Standards Board is a consortium of 9 environmental and business NGOs. We were set up in Davos in 2007 with a mission to create the enabling conditions for material climate change and natural capital information to be integrated into the mainstream report.
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What makes the TCFD different?
What the outcome of the TCFD is – improve decision-making (by investors, lenders and insurers in allocating capital and underwriting risk), enhance market resilience and more sustainable economic growth.
Also to ensure more stable, resilient markets over the medium and long term by facilitating a smoother transition—with less abrupt price adjustments—to a lower-carbon and climate-resilient economy.
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Previous environmental reporting Staff Notice unsuccessful
Final Report of the Expert Panel on Sustainable Finance
5.1. Endorse a phased ‘comply-or-explain’ approach to adoption of the TCFD framework in Canada.
5.2. Provide clarity to issuers on the recommended scope and pace of TCFD implementation.
5.3. Work with federal, provincial and industry partners to clarify the materiality of climate-related financial disclosures.
Canadian Business Corporation Act, Part XIV Financial Disclosure is updated with requirements for financial statements to include environmental disclosures; and/or
Updates to National Instrument 51-102 Continuous Disclosure Obligationsii and National Instrument 58-101 Disclosure of Corporate Governance Practices.
Updates to CSA Staff Notice 51-333 Environmental Reporting Guidanceiv to incorporate TCFD recommendations
AASB Practice Statement on Climate-related and other emerging risks disclosures
asset impairment;
changes in the useful life of assets;
changes in the fair valuation of assets due to climate-related and emerging risks;
increased costs and/or reduced demand for products and services affecting impairment calculations and/or requiring recognition of provisions for onerous contracts;
potential provisions and contingent liabilities arising from fines and penalties; and
changes in expected credit losses for loans and other financial assets.
MESA-LAB PÚBLICO-PRIVADA DE FINANZAS SOSTENIBLES EN CHILE
defining a long term agenda of dialogue and joint efforts between the government, Finance Ministry, central Bank of Chile, regulators like the Pensions Authority and our Commission for the Financial Markets, AND other financial institutions belonging to the private sector.
The objective is to incorporate the risks and opportunities of climate change in business strategies and investment decisions aligned with the recommendations of the working group of the Financial Stability Council of G20 about voluntary climate-related financial disclosures.
The Ministers and Advisors of the Comision para el Mercado Financiero (CMF) are in the final phase of a project that contemplates changes to the Norma de Carácter General n°30. These changes focus on tweaking the requirements of information related to social responsibility and sustainable development that corporations currently disclose in their annual report. The new requirements are aimed at delivering complete, consistent and decision-useful ESG information to investors so that they can incorporate this into their decision making. This will also help organisations become more resilient and sustainable in the long term.